Audit Report. Natural Resources Conservation Service Water and Climate Information System Review of Application Controls Portland, Oregon

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1 U.S. Department of Agriculture Office of Inspector General Western Region Audit Report Natural Resources Conservation Service Water and Climate Information System Review of Application Controls Portland, Oregon Report No SF December 2004

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3 Executive Summary Natural Resources Conservation Service Water and Climate Information System - Review of Application Controls (Audit Report No SF) Results in Brief This report presents the results of our audit of application controls within the Natural Resources Conservation Service s (NRCS) Water and Climate Information System (WCIS). Application controls are the measures an organization takes to provide for the safety, accuracy, and completeness of data within its information systems. Although, our review did not identify any concerns with the accuracy and completeness of data, we determined that management controls over system security were inadequate, leaving valuable data vulnerable to unauthorized access and alteration. Our audit disclosed conditions that need management action. Specifically, risk assessments were conducted according to outdated regulations. Security plans were not timely updated. Contingency plans to recover operations of WCIS in the event of major systems failures were not complete. The system had not been properly accredited or certified. Of most immediate concern, medium- and high-risk vulnerabilities should have been identified and mitigated as part of required periodic scanning. During conversations regarding these issues, the Chief Information Officer (CIO) (responsible for NRCS information systems) recognized that the agency lacked a mechanism to ensure that personnel were made aware of the relevant regulations (and changes to them). Such a control mechanism would provide the most up-to-date guidance available to personnel responsible for implementing regulations. In addition, the agency lacked a management oversight system that would as a matter of course involve the CIO in monitoring that the regulations were timely and properly implemented. For the risk vulnerabilities in the WCIS, such monitoring would have informed the CIO that field level personnel were not doing required tasks. Recommendation In Brief Establish controls to ensure that Office of Management and Budget (OMB), National Institute of Standards and Technology (NIST), and Departmental Information Technology (IT) security requirements are met, especially in the development of disaster recovery and security plans, risk assessments and the performance of vulnerability scans for all field units. Agency Response In its written response to the official draft report, dated October 27, 2004, NRCS generally concurred with the audit findings and recommendations. The complete written response is shown in exhibit A of the audit report. USDA/OIG-AUDIT/ SF Page i

4 OIG Position Based on NRCS written response, OIG accepts NRCS management decision for all audit recommendations, except for Recommendation Nos. 1 and 6. Additional information is needed in order to reach management decision on the two remaining recommendations. USDA/OIG-AUDIT/ SF Page ii

5 Abbreviations Used in This Report Center CIO CS GAO ISS ISSPM IT NRCS NIST OCIO OIG OMB USDA WCIS National Water and Climate Center Chief Information Officer Cyber Security (issued by OCIO) Government Accountability Office Information System Security Information System Security Program Manager Information Technology Natural Resources Conservation Service National Institute of Standards and Technology Office of the Chief Information Officer Office of Inspector General Office of Management and Budget United States Department of Agriculture Water and Climate Information System USDA/OIG-AUDIT/ SF Page iii

6 Table of Contents Executive Summary...i Abbreviations Used in This Report...iii Background and Objectives...1 Findings and Recommendations...3 Section 1. Management Oversight...3 Finding 1 NRCS Did Not Maintain Oversight or Control Over WCIS...3 Recommendation No Section 2. Security Weaknesses...5 Finding 2 Finding 3 Preventive Security Measures Did Not Meet Requirements...5 Recommendation No Recommendation No Recommendation No Recommendation No Recommendation No Recommendation No Vulnerability Scans Not Conducted...10 Recommendation No Recommendation No Scope and Methodology...12 Exhibit A NRCS Response to Draft Report...13 USDA/OIG-AUDIT/ SF Page iv

7 Background and Objectives Background USDA s Office of the Chief Information Officer (OCIO) is responsible for establishing, implementing, and overseeing a departmental-wide information security program, while the component agencies are responsible for the dayto-day management of information security for their mission-support systems. During 1999, USDA s Office of Inspector General and Government Accountability Office (GAO) found significant information security weaknesses at the Department s two major data centers, which placed critical assets at significant risk. In August 2000, the GAO released a report on USDA s information security to the Chairman, Subcommittee on Department Operations, Oversight, Nutrition, and Forestry, Committee on Agriculture, House of Representatives. The report, USDA Needs to Implement Its Departmentalwide Information Security Plan, states that automated systems are essential to USDA s operations and the delivery of its mission-critical programs, especially as it moves towards electronic government (e-government). One critical asset is NRCS Water Climate Information System (WCIS). WCIS is an extensive, automated system designed to collect snow pack and related climatic data in the western United States. The system evolved from NRCS's congressional mandate in the mid-1930's to measure snow pack in the mountains of the West and forecast the water supply. The program began with manual measurements of snow courses, but since 1980 it has relied on an automated system that has collected the data needed to produce water supply forecasts and to support the resource management activities of NRCS and others. The WCIS provides information related to climate studies, air and water quality investigations, and water resource management concerns. The highelevation watershed locations and the broad coverage of the network provide important data collection opportunities to researchers, water managers, and emergency managers for natural disasters such as floods. WCIS is maintained by NRCS National Water and Climate Center, located in Portland, Oregon. All data received by the WCIS central computer is linked to the Centralized Forecasting System where the public can access the data via the Center s homepage. USDA follows Federal systems security requirements set forth by the Office of Management and Budget (OMB). The National Institute of Standards and Technology (NIST) interprets OMB s requirements and issues guidance to foster compliance. USDA s OCIO passes the requirements and guidance to the agencies within the Department and ensures that the Federal requirements USDA/OIG-AUDIT/ SF Page 1

8 are met. Within NRCS, the CIO is responsible for informing field units of the OMB requirements and establishing controls to ensure the units respond to Department oversight and report to the OCIO on the status of systems security. Objective Our audit objective was to determine if the Water and Climate Information System s application controls are in place and are functioning to provide for accuracy, and completeness of system data. Our review did not identify any problem with the completeness and accuracy of the data once it was collected. During this audit, we expanded our original objective to: 1) determine if it was properly secured against unauthorized access and if its data was adequately protected from unauthorized alteration, and 2) assess the adequacy of management oversight of system security. USDA/OIG-AUDIT/ SF Page 2

9 Findings and Recommendations Section 1. Management Oversight Finding 1 NRCS Did Not Maintain Oversight or Control Over WCIS The information in NRCS Water and Climate Information System (WCIS) has neither been adequately secured from threats to data integrity, nor appropriately prepared to recover in the event of major system failure. Although there is a wealth of Federal and Departmental guidance designed to obviate these concerns, NRCS Chief Information Officer (CIO), due to a variety of circumstances described below, did not have controls in place to affect the appropriate policies and procedures, or to monitor their implementation. As a result, the agency cannot be assured of the integrity of data used, for example, by farmers to prepare for drought, emergency workers to anticipate flooding, and reservoirs to manage water reserves. Following Federal regulation, the Department level OCIO enforces Federal policies and procedures for securing information systems. The OCIO distributes its guidance to the agency level NRCS CIO who bears overall responsibility for making sure that it is put into practice within the agency. Following the OCIO s lead, NRCS CIO should disseminate the requirements either directly or through NRCS s Information System Security Program Manager (ISSPM) to information systems team leaders in the field who carry out the security instructions. The team leaders should then communicate back up through the chain of command so that the CIO can ensure that the systems are secured according to regulation. Information System Security Management Over WCIS Office of the Chief Information Officer US Department of Agriculture (enforces Federal policies and procedures for securing information systems) Chief Information Officer (CIO) National Resources Conservation Service (NRCS) (ensures that policies and procedures are effected) Information System Security Program Manager (ISSPM) NRCS (carries out CIO's direction and provides a liason with the field) Information System Team Leader National Water and Climate Center (implements security direction from management and maintains Water and Climate Information System (WCIS)) Our audit determined that NRCS CIO did not provide the field level team leader with OCIO direction regarding contingency plans, security plans, USDA/OIG-AUDIT/ SF Page 3

10 Recommendation No. 1 system certification, and risk assessments (see finding 2 below). In addition, when there were OCIO instructions provided to scan the Water and Climate Information System each month, the CIO did not maintain management oversight to make certain that the job was done. As a result, the system was not properly secured. When we scanned the system during our audit, we found two high-risk and one medium-risk vulnerability that could have been exploited to gain access to sensitive data and possibly allow the system to be compromised. The details are described in Finding 3 of this report. Establish controls to communicate Federal and Department level security guidance to field level units and develop an oversight system to ensure compliance. Agency Response. NRCS response stated that the CIO does not have direct line authority to direct, control, and manage operations of the WCC (National Water and Climate Center). The response added that this issue is a leadership call to address, mitigate, and correct as leadership deems appropriate. OIG Position. NRCS response did not address the audit recommendation. In order to reach management decision, NRCS needs to provide OIG with the specific controls that NRCS plans to establish that will communicate all NIST and USDA security requirements to the field level units as well as the timeframes when the controls will be implemented. USDA/OIG-AUDIT/ SF Page 4

11 Section 2. Security Weaknesses Without proper controls, the Water and Climate Information System is at risk of being compromised. As previously described, NRCS CIO is responsible for effecting and monitoring the agency s information system security but did not have adequate mechanisms in place to communicate Department level security guidance to the field level where that guidance is implemented. As a result at that time of our audit, the Water and Climate Information System was not adequately secured. Finding 2 Preventive Security Measures Did Not Meet Requirements The National Water and Climate Center (Center) did not properly prepare to recover the WCIS in case of disaster, update security plans to safeguard the WCIS, certify the WCIS, or assess the WCIS for risks. In each case, information system team leader stated that he had not been made aware of security requirements (or changes to the requirements). Without the safeguards developed by the Department to protect it from known risks, NRCS WCIS remained unnecessarily vulnerable and less likely to recover should its vulnerability be exploited. The Office of Management and Budget (OMB) Circular A-130 sets general Federal security requirements for information systems, and the National Institute of Standards and Technology (NIST) issues guidance that translates those requirements into more specific steps 1 (OMB A-130 states agencies must implement NIST guidance) Departmental requirements (manuals, directives, etc.) further formalize these rules into policies and procedures. Our audit determined that several security measures undertaken by the Center did not meet the above requirements. Contingency Plans OMB A requires agencies to plan for how they will continue to perform their mission or recover from the loss of application support in the event of a system failure. NIST 3 states that general support systems require contingency plans. It also states that contingency plans should be tested since untested or outdated contingency plans create the false sense of a system s ability to recover in a timely manner. 1 OMB A-130, Appendix III, dated November 30, OMB A-130, Appendix III, dated November 30, NITS SP , Guide for Developing Security Plans for IT Systems, dated December USDA/OIG-AUDIT/ SF Page 5

12 Cyber Security (CS) issued by the OCIO requires the agency to develop and implement an executable IT Disaster Recovery Plan for each critical application. NIST 5 specifies that Disaster Recovery Plans apply to major, usually catastrophic, events that deny access to the normal facility for an extended period, and for disruptions that require relocation. WCIS contingency plan did not indicate how the agency intends to recover the system in the event of catastrophic system failure. NRCS CIO said that due to workload and other priorities, she was unable to monitor the contingency plan development to ensure that was progressing as required by OMB and NIST regulations. The CIO did state that NRCS is negotiating with a contractor to develop an appropriate disaster recovery site, but the contract had not been signed as of the date of our review. In addition, the information systems team leader said that the team was in the process of getting the disaster recovery plan completed by April Security Plans OMB A-130 requires agencies to prepare a security plan. According to NIST, 6 there should be a policy that requires the production, update, and review of system security plans on a periodic basis or when the systems are implemented or significantly changed. CS requires all Security Plans be submitted to the OCIO by April each year. The Center did have one overall general security plan for its network, but the security plan was not properly reviewed, approved, updated, or submitted annually. The security plans for WCIS lacked documentation that indicated who approved the changes (name and title of approving management official and date of approval). The information systems team leader stated he was not aware that the security plans needed formal written certification and approval whenever updates and changes were made. The Center did not have a policy that required updates and review of system security plans on a periodic basis. Although the Center had security plans there was no evidence indicating that it had periodically reviewed the security plans since CS-028, IT Contingency and Disaster Planning, dated 5/23/03, Referenced to DR 3500, Chapter NIST SP , Contingency Planning Guide for Information Technology Systems, dated June NIST SP , Guide for Developing Security Plans for IT Systems, dated December CS-025, Cyber Security Plan, dated March 31, 2003 Referenced to DM 3500, Chapter 13. USDA/OIG-AUDIT/ SF Page 6

13 NRCS CIO confirmed our determination that due to workloads and other priorities, controls had not been established to ensure that the security plan was updated according to NIST guidelines and that the updated plan was submitted to the Department on an annual basis. Certification and Accreditation OMB Circular A states that accreditation of a system to process information provides an important quality control. The USDA Certification and Accreditation Guide 9 requires agencies to ensure that a management official authorizes the use of each system before beginning or significantly changing processing in the system. Use of the system must be re-authorized at least every 3 years. Although WCIS has been in use since 1980, the system had not been certified and accredited. The information system team leader was unaware of the requirement until September 2003 at which time a contract was written to have this work done. Subsequently, the CIO directed the Center to certify and accredit WCIS, and the team leader informed us that he anticipates completion in September Risk Assessments NIST s October 2001 Risk Management Guide requires that a risk assessment include: 1) the identification of threats and vulnerabilities; 2) the identification and analysis of security controls; 3) the analysis of impact or magnitude of harm that a loss of confidentiality, integrity, or availability would have on operations (including mission, functions, image, or reputation), assets, or individuals; 4) the likelihood of threat exploitation of vulnerabilities; and 5) determination of risk. 11 CS states that a formal system risk analysis is required every three years or when a major change in made in a system. Major changes are defined as modifications to the system that affect the security controls and which render the system vulnerable to compromise or intrusion. In 2002, when Center staff conducted a risk assessment for WCIS, they did not do so according to the above NIST requirements. Instead, they relied on a previous assessment prepared by a contractor before the October 2001 requirements were in place. When we questioned the CIO about the risk assessment, she stated that she had not established controls to ensure that risk assessments had been properly completed. 8 OMB A-130, Appendix III, Section B(a)4, dated November USDA Certification and Accreditation Guide, dated June 2, OMB recently tied C&A to budget (funding) availability and the USDA set a goal of having all systems certified and accredited by 9/30/04 11 NIST SP , dated October CS-031, Chapter 8, Risk Management Program, dated July 7, 2003 USDA/OIG-AUDIT/ SF Page 7

14 Recommendation No. 2 Recommendation No. 3 Recommendation No. 4 Overall, the CIO did not communicate current policies and procedures to field level staff responsible for implementation. During our review, we found that WCIS had issued a contract to have an independent contractor develop the contingency plan, security plan and risk assessment by June 30, 2004, so that the WCIS can be certified and accredited by September 30, Develop a disaster recovery plan in accordance with OMB and NIST requirements as part of the contingency plan and test the complete contingency plan once developed. Agency Response. The WCIS Certification and Accreditation was completed on September 30, 2004, with the IT Contingency/Disaster Recovery Plan testing being completed in April 1, OIG Position. We accept NRCS management decision on this recommendation. The estimated final action date is April 1, Establish a formal approval process for security plans that documents the name and title of the approving management official and the date of approval and follow Departmental Regulations. Agency Response. The NRCS IRM Security Manual and the National IRM Manuals are scheduled for review and updates in accordance with current Departmental policy and NIST guidance. Both manuals will incorporate language relative to Certification and Accreditation, by December 30, OIG Position. We accept NRCS management decision on this recommendation. The estimated final action date is December 30, Implement procedures requiring that the security plan be reviewed, updated, and certified per NIST guidelines and that updated plans be submitted to the OCIO on an annual basis. USDA/OIG-AUDIT/ SF Page 8

15 Recommendation No. 5 Agency Response. The NRCS IRM Security Manual and National IRM Manuals are scheduled for review and updates in accordance with current Departmental policy and NIST guidance. Both manuals also will incorporate language relative to Certification and Accreditation and Security Plan updates, by December 30, OIG Position. We accept NRCS management decision for this recommendation. The estimated final action date is December 30, Perform a Certification and Accreditation (C&A) on the WCIS system per OMB regulations and USDA guidance. Agency Response. The Certification September 30, and Accreditation on WCIS was completed on Recommendation No. 6 OIG Position. We accept NRCS management decision for this recommendation. The final action date was September 30, Establish controls to ensure that use of the WCIS system is reauthorized every 3 years. Agency Response. Once Certification and Accreditation for WCIS is completed, NRCS will work on a continual basis to ensure that WCIS is reauthorized every 3 years according to USDA and NIST policies and regulations. OIG Position. In order to reach management decision on this recommendation, NRCS needs to provide an estimated completion date on when the controls will be established. USDA/OIG-AUDIT/ SF Page 9

16 Recommendation No. 7 Complete risk assessments of the WCIS that will meet NIST, OMB and USDA requirements. Agency Response. The NRCS security team conducted a Risk Assessment on WCIS during July 2004, and will maintain these requirements per USDA and NIST policies and regulations. OIG Position. We accept NRCS management decision on this recommendation. The final action date was July Finding 3 Vulnerability Scans Not Conducted Monthly vulnerability scans of the WCIS were not conducted (vulnerability scans analyze a computer system to identify well-known security weaknesses). The Center s staffs had guidance requiring them to perform these scans on a monthly basis, but they were not performing them. Since the CIO did not have an oversight mechanism in place (e.g., monthly reporting of scan results), the lack of compliance continued until the time of our audit. Without the scans to timely identify serious weaknesses, the system had a significant risk of being compromised. USDA Departmental Manual 13 states, information system security (ISS) scanner software will be run on a monthly basis on all computer systems. Cyber Security Policy and Procedure 14 states agency management or the CIO will ensure that all agency/staff offices order and use the software to conduct ISS scans on a monthly basis. In February 2004, we interviewed the information systems team leader and learned that the Center had just completed its first ISS scan of WCIS. The team leader stated that there had been no guidance from the CIO to make sure that the monthly scans were done. On February 23, 2004, the day we arrived to begin our audit Center staff obtained the scanning software which had been available since 2001 and ran the vulnerability scan. The software detected two high-risk vulnerabilities 13 Departmental Manual , Chapter 6, dated April 4, OCIO CS-007, dated September 5, 2001 USDA/OIG-AUDIT/ SF Page 10

17 Recommendation No. 8 Recommendation No. 9 and one medium-risk vulnerability. 15 We confirmed their results during two separate scans in March Require responsible officials to timely submit verification to the CIO that monthly vulnerability scans have been run on WCIS. Agency Response. A monthly report on scan activity will be reported to the CIO by the NRCS ISSPM. The action is to be completed by December 30, OIG Position. We accept NRCS management decision on this recommendation. The estimated final action date is December 30, Take immediate action to correct the high- and medium-risk vulnerabilities identified by the scans and conduct an immediate rescan to ensure that the vulnerabilities have been corrected. Agency Response. On the two high-risk vulnerabilities identified by the scanning software: a) one was found to be a false positive indicating the vulnerability did not exist, and (b) the second high-risk vulnerability involved the presence of system services, which are required to meet a business requirement and function of WCIS. This vulnerability was mitigated by ensuring that no shell interpreters were in the root/cgi-bin, in accordance with the accepted security practices, and this mitigation was in place at the time of the scans. On the medium vulnerability, it also involved the existence of a required service running on the server. This server has been patched to mitigate this medium vulnerability. OIG Position. We accept NRCS management decision for this recommendation. The final action date was October High-risk vulnerabilities are those that could allow access to the computer and possibly to the network of computers. Medium-risk vulnerabilities are those that could allow access to sensitive network data that may lead to exploitation of other vulnerabilities USDA/OIG-AUDIT/ SF Page 11

18 Scope and Methodology For this audit, we reviewed the adequacy of application controls over the Center s WCIS network. We selected the WCIS for review because the parent agency, NRCS, had identified this system as a major application needing to be certified and accredited. This audit of NRCS is part of a nationwide audit of USDA mission-critical systems. A nationwide audit report will be issue to the Department s Office of the Chief Information Officer by OIG s Financial and Information Technology Operations and might include sections of this report. This review was performed at NRCS Center located in Portland, Oregon. Fieldwork was performed from February 23, 2004, through March 25, Our review included an evaluation of the data within the WCIS to determine if it was complete and accurate once it was collected by the sensors located in the snow pack in the mountains. We did not evaluate the sensors themselves to determine their reliability at the collection stage. Our review did not identify any problems or concerns with completeness and accuracy of the data once it was collected. During the audit, we expanded out objective to review the overall security of system data, including management oversight of system security. To accomplish our audit objectives, we performed the following audit steps and procedures: We reviewed IT security policies and procedures from the Department s Office of the Chief Information Officer, OMB, NIST, and USDA Departmental Manual. We interviewed responsible NRCS officials managing the WCIS. We performed ISS vulnerability scans on the WCIS. We analyzed records and controls (Contingency Plan, Security Plan, Risk assessment and Certification and Accreditation Process) established to ensure the data integrity of the WCIS. This audit was performed in accordance with generally accepted government auditing standards. USDA/OIG-AUDIT/ SF Page 12

19 Exhibit A NRCS Response to Draft Report Exhibit A Page 1 of 6 USDA/OIG-AUDIT/ SF Page 13

20 Exhibit A NRCS Response to Draft Report Exhibit A Page 2 of 6 USDA/OIG-AUDIT/ SF Page 14

21 Exhibit A NRCS Response to Draft Report Exhibit A Page 3 of 6 USDA/OIG-AUDIT/ SF Page 15

22 Exhibit A NRCS Response to Draft Report Exhibit A Page 4 of 6 USDA/OIG-AUDIT/ SF Page 16

23 Exhibit A NRCS Response to Draft Report Exhibit A Page 5 of 6 USDA/OIG-AUDIT/ SF Page 17

24 Exhibit A NRCS Response to Draft Report Exhibit A Page 6 of 6 USDA/OIG-AUDIT/ SF Page 18

25 Informational copies of this report have been distributed to: Government Accountability Office (2) Office of Management and Budget (1) Office of the Chief Financial Officer Director, Planning and Accountability Division (1)